Perhaps it was the farmers’ demonstrations or the piles of farmyard manure in Brussels, but the European Commission has reversed its opposition to certain crop based biofuels. Recently published Delegated Acts update the Renewable Energy Directive, to allow biofuels made from intermediate crops and those grown on degraded land, to be eligible to count against EU countries’ targets for renewable energy. This is a big step forward, but the details suggest that all is not what it seems. In particular, farmers and small companies may not be the main beneficiaries.
Interest is focussed on intermediate crops, which include cover crops that are grown over winter to improve soil health and catch crops that absorb excess nitrogen and reduce run-off. But, as always, the devil will be in the detail, because too many restrictions can make the new opportunities unattractive. To be eligible, intermediate crops must be grown in areas where ‘the production of food and feed crops is limited to one harvest’ and their use as raw materials for energy does not create a demand for extra land. The soil organic matter content must also be maintained.
So, there will be conditions, necessitating a further publication from the Commission laying out the evidence farmers will need to prove they comply. Judging from past decisions, expensive tests may be required to show that the soil condition has not changed. Proving that there is no demand for extra land will probably entail evidence of no decrease in yields of the main crop and no increases in cultivated land area into the future. And farmers will have to show that they have historically been harvesting only one main crop per year.
The Commission has, for a long time, clung to the myth that there are enough biogenic wastes to provide raw materials for sustainable aviation fuel, marine fuels and road transport that cannot easily be electrified. And that companies will invest heavily in ‘e fuels’ or other advanced technologies undeterred by flip-flopping in official policy. Unfortunately, despite the about-turn on intermediate crops, incorrect thinking is still in evidence. The new feedstocks have been approved in a way that favours their use for aviation rather than road transport. So, farmers and processors hoping to produce biogas or biodiesel will be disappointed.
The industry associations for biodiesel producers, which are mainly small and medium sized companies, have indicated that this classification will impact adversely on marine and heavy goods transport and queried how it will be effectively policed. The classifications of feedstocks/technology/sector combinations as mature or immature are disingenuous. For example, technology for the conversion of oil seeds, such as carinata, into aviation fuel are deemed to be immature, when other oil seeds such as palm, have been processed similarly at a commercial scale for many years.
The list of acceptable feedstocks for biofuels into the future has also been expanded to include other processing wastes from the food and drinks industries. This is good news, but again, processing routes have been incorrectly labelled as ‘mature technologies’ which caps their overall use. The difficulties of purifying wastes and adapting existing technology to cope with recently approved raw materials have been underestimated by the European Commission and its experts, to the detriment of the industry. Small and medium companies are key to the exploitation of new wastes, and, as I have written before, such decisions undermine the principles of the Circular Economy.
The change in official policy in favour of certain crop based biofuels has been welcomed, particularly as it was taken despite a study that was rather negative about intermediate crops. However, the changes favour the large companies that make up the aviation sector’s supply chain. And the conditions imposed are likely to reduce the take-up of the new freedoms. Given the background to the decision, perhaps this was always the intention.
Published: 29 March 24
